Definition of "control" under the consolidation and controlled foreign company regimes.
01 Mar 06 |
NEW ZEALAND JOURNAL OF TAXATION LAW AND POLICY
Issue: Vol. 12 no. 1 2006
Pages: pp. 37-60
Income tax systems in general treat companies as separate taxpayers. However, the consolidation and the controlled foreign company (CFC) regimes override the separate legal entity principle and tax companies under some form of attribution system. In this article, the author examines one of the critical issues in respect of these two specific regimes, that is, the definition of "control" of companies. The author critically reviews and compares the definitions of "control" under the consolidation and the CFC regimes in three countries: Australia, New Zealand and the United States.
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Antony is a senior lecturer, discipline of business law, University of Sydney.
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01 January 2014